ML20217G248

Insp Repts 50-254/98-05 & 50-265/98-05 on 980216-0326. Violations Noted.Major Areas Inspected:Engineering,Including Allowances for Development of Emergency & Immediate Mods

ML20217G248
Person / Time
Site:	Quad Cities
Issue date:	04/23/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217G186	List: ML20217G183 ML20217G234 ML20217G248
References
50-254-98-05, 50-254-98-5, 50-265-98-05, 50-265-98-5, NUDOCS 9804290097
Download: ML20217G248 (11)

See also: IR 05000254/1998005

Text

-

-

.

.

.

.

U. S. NUCLEAR REGULATORY COMMISSION

REGION 111

Docket Nos: 50-254;50-265

License Nos: DPR-29; DPR-30

Report No: 50-254/98005(DRS); 50-265/98005(DRS)

Licensee: Commonwealth Edison Company (Comed)

Facility: Quad Cities Nuclear Power Station, Units 1 and 2

Location: 22710 206th Avenue North'

Cordova, IL 61242

Dates: February 16,1998 - March 26,1998

Inspector: J. Guzman, Reactor inspector

l Approved by: John Jacobson, Chief

l Lead Engineers Branch

l

9804290097 900423

PDR ADOCK 05000254

G PDR

.

.

.

EXECUTIVE SUMMARY

Quad Cities Nuclear Power Station, Units 1 & 2

NRC Inspection Report No. 50-254/98005(DRS); 50-265/98005(DRS)

Enaineerina

. Allowances, with precautions, for development of emergency and immediate

modifications were adequately accounted for in the Quad Cities QA Program and in

corporate and station procedures. Use of these types of modifications was not common

and, when used, adequate controls existed to ensure minimum prerequisites, limitations,

and operational restrictions were considered, including completion of 10 CFR 50.59

screenings or safety evaluations.

. Adequate controls were in place to ensure that at-risk work packages developed in

parallel with the design package would assure cornponents would not be declared

operable until completion of all design documentation. Use of the at-risk process was

not routine and work completed appeared well-coordinated between the work analyst,

design and construction staff. While generation of at-risk work packages was allowed

by the Work Request initiation procedure, at-risk work was contrary to the Plant Design

Change Process procedure. This was considered a procedural adherence violation.

l

2

i

.

,

.

Report Details

lli. Engineering

E1 Conduct of Engineering

E1.1 Review of Emergency Modifications and At-Risk Work Process

a. Inspection Scoce

The inspector reviewed the Quad Cities engineering modification and at-risk work

processes to ascertain compliance to the Quad Cities OA manual, as well as to

corporate and site procedures. The inspector focused on three vehicles used for

expediting design work at Quad Cities, namely (1) emergency modifications, (2) at-risk

work requests and (3) immediate modifications.

l

The inspector reviewed a sample of modifications developed as emergency

modifications and work packages completed using the at-risk work process. Associated

problem identification forms (PIFs) were also reviewed as were NRC commitments

related to design modifications. The inspector interviewed licensee staff cognizant with

the development of design modifications, work package preparation and work package

installation. Corporate and site procedures and other documents related to the design

change process were also reviewed including:

. " Preparation and Control of Work Packages," QCAP 2200-04, Rev.17

. " Action Request / Work Request Initiation," QCAP 2200-02, Rev.12

. " Plant Design Change Process," QCAP 0460-01, Rev. 6

. " Emergency Modification to Support Appendix R," Letter dated October 28,1998

Doc. ID: Q-ECDS-97-0613

. " Engineering Requests," QCAP 0440-01, Rev.10

. " Comed QA Program Topical Report CE-1-A," Dated January 23,1998 j

- " Plant Modifications," NEP-04-01, Rev. 5 i

b. Observations and Findinos

b.1. Review of OA Manual and Corocrate Procedures

The inspector reviewed licensee commitments and requirements of corporate

procedures as well as the QA manual to verify allowances related to use of (1)

emergency modifications, (2) at-risk work requests and (3) immediate modifications.

. Section 3.3 of the Comed Quality Assurance Manual Quad Cities (Topical

Report CE-1-A, dated January 23,1998) required that " design verification for the '

l stage of design activity accomplished shall be performed prior to release for

procurement, manufacture, construction or release to another organization for

i

use in other design activities provided sufficient data exists." The QA Manual

also added:"Any unverified portion of the design shall be identified and

controlled."

!

3

<

.

d

.

. Comed corporate procedure NEP-04-01, " Plant Modifications," Revision 5

provided guidance on use of emergency modifications. Section 5.2.5 of this

procedure specified that "if an emergency modification is required and authorized

by Management, advanced approval may be given to start installation work. The

design supervisor shall determine the documents required to start emergency

installation work." This procedure provided minimum requirements which

included:

. the specific work being authorized,

. prerequisites and limitations for the work being authorized,

. operating restrictions on the system pending completion of the

modification, and  ;

. a completed 50.59 evaluation for the scope of work authorized by the

]

advanced approval.

i

Per the procedure, "the package approved by the design supervisor shall be

issued when the modification design is completed. Minimum requirements are

the design documents, the Design Change Approval and Closecut Form, and the

50.59 Safety Evaluation."

. Comed corporate procedure NEP-04-01, " Plant Modifications," Revision 5,

Section 5.2.1.21 states "If authorized by Management, at-risk changes may be

installed prior to full regulatory approval; however, the change shall not be

retumed to operation until complete and formal regulatory approval is required."

. Using the Nuclear Documents (NUDOCS) system and references from the

Comed Nuclear Tracking system, the inspector also reviewed Comed

commitments to the NRC. This review was made to determine whether use of

emergency modifications or at-risk work was contrary to any commitments that

Comed had made to the NRC such as corrective actions for past design and

design control problems. None were identified.

The inspector concluded that adequate allowances and controlling limitations for

development of emergency and immediate modifications were accounted for in the

Quad Cities QA Program and in corporate procedures,

i b.2. Quad Cities Use of Exoedited Design Process and Review of Site Procedures

The three vehicles used at Quad Cities that could potentially bypass the design process

i were (1) emergency modifications, (2) at-risk work requests and (3) immediate

, modifications.

Emergency Modifications

Emergency modifications at Quad Cities were developed using the guidance of

Corporate Procedure NEP 04-01, " Plant Modifications," The inspector observed that the

word " emergency" was not defined and use of emergency modifications was at the

discretion of plant management. However, emergency modifications were infrequently

used and their use to expedite the schedule during the Fall 1997 recent Appendix R

compliance issues was not considered unreasonable. The inspector did not review the

I

.

.

overall Appendix R effort or other aspects related to the safe shutdown analysis, but did

review a sample of design packages for content, hold points and other limitations and

did not identify any design process deviations for emergency modifications.

At-Risk Work

At Quad Cities, development of at-risk work packages was done under the auspices of

procedure QCAP 2200-02," Action Request / Work Request Initiation." The licensee

defined at-risk work as work completed at " commercial risk" prior to all work control

documents being approved. The work can be performed at the Plant Manager's

discretion after analyzing the risk. Per the procedure, the work would be done only on

components that are inoperable and the design documentation must be completed pnot

to returning the component to service. The PlF process would be used as an available

mechanism to control at-risk work to ensure that the inoperable compor ants were not

declared operable prior to completion of all design documentation. Adctionally, l

Attachment C of the procedure would be completed to describe the wock description, l

justification for the work, and discussion of the commercial risk involved

The inspector determined that implementation of the at-risk work package option had

been infrequent. Based on interviews, the inspector also noted that the licensee

wrestled with whether to use at-risk work requests during the Appendix R modifications

and ultimately decided to use the at-risk option for fabrication and procurement only and

not for installation. This decision stemmed from the Appendix R modification that routed

cable trays along the power block. Installation of anchor bolts on concrete walls on an

at-risk basis was contemplated since the design package was not completed. Internal

debate among licensee staff resulted in a decision to wait for the modification package i

to be complete in lieu commencing installation. This was due to the fact that the

concrete wall was not conducive to being declared inoperable. The licensee concluded

that the at-risk process could not readily be used on walls or other components or

systems that were not readily isolatable or could not be readily declared inoperable.

Subsequently, for Appendix R related components or structures, use of at-risk work

packages was confined to at-risk fabrication and at-risk procurement and not

installations.

A sample review of these packages and interviews with licensee staff indicated that for

at-risk work packages, the work analyst, the design engineer and the construction staff

worked in unison and the at-risk work packages were not generated or installed in a

" vacuum " The inspector noted that for at-risk work completed, there was minimal

likelihood the installation work would not be approved or qualified or would change

during the approval process. For example, the inspector reviewed in detail Work

Package 970104149-03 which replaced the 3/4" recirculation loop sample valve,

AO-2-0220-44, under at-risk conditions. Primarily due to lack of vendor seismic report

information, the package was generated and installed between October 6 through 10,

1997 in parallel with development of the design modification package, DCN 001581M,

which was approved on October 14,1997.

The inspector observed that the details for preparation and control of at-risk work

packages did not change from regular work packages. The work analysts continued to

use the precautions and limitations of procedure QCAP 2200-04," Preparation and

Control of Work Packages," during development of the at-risk work packages.

5

.

'

1

I

l

Additionally, precautions and limitations, design considerations, QC hold points, test

requirements, technical reviews and structures, systems and component boundaries

were appropriately handled.

1

Use of at-risk work packages was first allowed in 1996 by Revision 8 of QCAP 2200-02,

l " Action Request / Work Request Initiation." As discussed above, with the components

declared inoperable, at-risk work was not considered contrary to Comed QA

requirements. The inspector noted that upon implementation of the at-risk option at

Quad Cities, the licensee did not revise all applicable design change procedures.

Specifically, QCAP 0460-01, " Plant Design Change Process," Step D.4.a continued to

require that the installer receive an aooroved design change package prior to work

package preparation. Development of at-risk work was, therefore, contrary to

QCAP 0460-01. The at-risk work package reviewed in detail, Work Package

! 970104149-03, was considered a procedural adherence violation contrary to 10 CFR 50,

Appendix B, Criterion V, " Instructions, Procedures, and Drawings" (VIO 50-254/98005-

01; 50-265/98005-01(DRS)).

Immediate Modifications

Designation of a modification as an "immediate" modification was a third vehicle used to

expedite design changes. These modifications were not " emergency" modifications but

rather full modifications that would not be presented to the Technical Review

Board (TRB)/ Site Planning Group (SPG) until up to one month after initiation instead of

prior to the start of the modification development. This bypass required approval by the

Site Vice President and was primarily an administrative bypass since "immediate"

modifications would still get an On-Site review prior to issuance of the MAL. Use of the

"immediate" modification option was also not common and use was limited to instances

where the normal TRB/SPG approval process would create unacceptable delay in

processing the change. "Immediate" modifications appeared adequately controlled and

proceduralized including a requirement for generation of a PIF as a mechanism for

documenting the urgency and to ensure TRB/SPG review occurs within one month. The

inspector did not identify any regulatory commitment or requirement specifying that the

TRB/SPG review occur prior to modification development.

c. Conclusion

Allowances, with precautions, for development of emergency and immediate

modifications were adequately accounted for in the Quad Cities QA Program and in

corporate and station procedures. Use of these types of modifications was not common

and, when used, adequate controls existed to ensure minimum prerequisites, limitations,

and operational restrictions were considered, including cornpletion of 10 CFR 50.59

screenings or safety evaluations.

Adequate controls were in place to ensure that components would not be declared

i

'

operable until completion of the all design documentation when at-risk work packages

were developed in parallel with the design packages. Use of the at-risk process was not

routine and work completed appeared well-coordinated between the work analyst,

design and construction staff. While generation of at-risk work packages was allowed

by the Work Request Initiation procedure, at-risk work was contrary to the Plant Design

Change Process procedure. This was considered a procedural adherence violation.

6

l

1 .

.

! E8 Miscellaneous Engineering issues

l E8.1 (Closed) Unresolved item (URI 50-254/94004-16: 50-265/94004-16): Review of

I

evaluations of piping with potential to leak over safety related switchgear. The inspector

verified that the licensee completed a series of walkdowns of susceptible switchgear and

verified that susceptible floor slab piping penetrations were adequately sealed. The

licensee walkdowns also revealed heating lines that appeared to require additional

supports. To address this, the licensee added supports in one case and, in another

case, a stress analysis was generated to demonstrate that additional supports were not

needed. This item is closed.

E8.2 (Closed) Insoection Followuo item (IFl 50-254/94004-29: 50-265/94004-29): High

Emergency Diesel Generator Cooling Water (EDGCW) pump flow evaluation did not

consider negative effects on EDGCW Heat Exchangers. In response, the licensee i

contacted the EDG vendor and satisfactorily evaluated the higher flow conditions to

conclude that the observed higher flows (1680 gpm vs. a baseline of 1500 gpm) were

acceptable. High flows were noted again in January 1995 when the Unit 1 EDGCW

pump quarterly flow rate test indicated that the pump was performing in a region beyond

the analyzed pump curve. These high flows were attributed to a throttle valve that was

incorrectly positioned as wide open. The inspector reviewed licensee procedure

changes to ensure positive controls on the throttle valve position were implemented.

Also reviewed were the last four Unit 1 quarterly flow rate tests that confirmed that the

pump was consistently operating within the acceptance criteria. This item is closed.

,

'

E8.3 (Closed) Unresolved item (URI 50-254/94004-32: 50-265/94004-321: RHR Containment

Isolation Valve not seat leak tested. The inspector reviewed the licensee scope and test

acceptance criteria for the IST and Appendix J programs. IST acceptance criteria for

stroke time and position indication and recent test data was satisfactory. The inspector

confirmed that the RHR 1(2)-1001-28 A, B valves were sealed with a qualified seal

water system. The inspector also confirmed that the RHR 1(2) 1001-07 A, B, C, D

pump suction valves were located on a line below the minimum suppression pool level

ensuring a potential pathway would be water-filled post-accident. Thus it was

acceptable to exclude the valves from LLRT testing. This item is closed.

E8.4 (Closed) Insoection Followuo item (IFl 50-254/94004-44: 50-265/94004-44):

Inadequate Prioritization, Trending and Status Control of the Site Engineering Service

Requests (SESR) Process. The inspector noted that SESRs are now part of the

Integrated Quality Report (lOE). lOE monthly performance review reports were

reviewed by the inspector who confirmed that on a monthly basis, the site satisfactorily

tracks and trends open, overdue, and the average age of open SESRs. Weekly reports

of overdue SESRs were printed with IQE color coded windows highlighting the number

of overdue SESRs. Prioritization was appropriately addressed via the Engineering

Request screening committee. This item is closed.

,

j E8.6 (Closed) Insoection Followuo item (IFl 50-254/94004-49: 50-265/94004-49): Corporate

Engineering Support Weaknesses. The licensee had initiated several improvement

efforts and management changes to address corporate engineering support

weaknesses, such as peer group reviews, Integrated Strategic Planning and

development of the Management Review Board. Improvements had occurred in the

interface between corporate and site personnel, with a primary example being the

7

l

.

4

.

ongoing effort expended in resolution of the Appendix R issue. However,

comprehensive and effective resolution of deficiencies identified by the Vulnerability

Assessment Team, the Diagnostic Evaluation Team, and the QC Course of Action

(COA) continued to be a concern. These deficiencies were discussed in the Licensee's

letter to the NRC dated January 2,1998 (SVP 98-002). Efforts to determine why

actions taken were not fully effective in providing a framework for longer term

continuous improvements were under licensee review. These efforts will be evaluated

as part of the core program using inspection Procedure 37550. This item is closed.

E8.7a (Closed) Violation (VIO 50-254/94020-03a: 50-265/94020-03a): Failure to correct RHR

2B minimum flow check valve after failed IST test. The inspector confirmed that, after

check valve refurbishment, the subsequent IST and operability tests were successful.

Further the inspector confirmed that the licensee's Restart Checklist was implemented

to ensure that open corrective maintenance work requests were reviewed for potential

impact on unit startup and power operations. This item is closed. ,

E8.7b (Closed) Violation (VIO 50-254/94020-03b: 50-265/94020-03b): Inadequate corrective

actions with Stand By Liquid Control (SBLC) system relief valves'setpoint drift problem.

The inspector reviewed actions taken to minimize setpoint drift including: cessation of

system flushing prior to checking the setpoint, installation of heat tracing on the relief

valves to address crystallization in the valve internals, trending of test results and failure

events, and bench testing of the relief valves in lieu of testing on the system. Based on

the testing and trending data, other actions to further minimize setpoint drift were still

contemplated. However, the inspector concluded that actions taken were satisfactorily

addressing and minimizing the setpoint drift. This item is closed.

E8.7c (Closed) Violation (VIO 50-254/94020-03c: 50-265/94020-03c): Administrative closure

of PlF resulting in failure to evaluate and correct RCIC rupture disc flange and seating

surface . The inspector reviewed the actions taken in response to the violation and

noted that since the 1994 violation an siectronic PlF system had been implemented j

which should facilitate communication of PlFs' status to all departments and minimize l

similar administrative closures. The inspector also observed that for this violation, the j

administrative closure of the Level IV PlF did not prevent the implementation of

corrective actions. An evaluation was completed to address the potential condensate

accumulation on the RCIC turbine and rupture disc which satisfactorily concluded that

the condensate collected would not significantly impact the turbine or rupture disc

functionality. The RCIC rupture disks and pipe flanges were replaced for both units. l

Additionally, the Unit 1 RCIC steam exhaust piping was inspected and a similar concern

was not identified. This item is closed

E8.8 (Closed) Violation (VIO 50-254/94020-04a. b: 50-265/94020-04a.b): Two examples of

10 CFR 50.55a(f)(4)(ii) violations (ASME IST Requirements). In the first example, the

licensee's failure to adequately test the SBLC system pumps' 1 A and 28 discharge

check valve was satisfactorily addressed by disassembling and inspecting the valves.

The check valves were replaced with a spring-loaded check valve design. The inspector

observed that the closed function test method of the check valves had been revised and

the test procedures had also been satisfactorily revised. The valves were no v tested by

establishing a vent path upstream of the applicable check valve while operating the

8

.

4

.

other loop's pump and monitoring the change in its flow rate. Further, the inspector

confirmed that the last surveillance tests for each unit were satisfactory. This item is

closed.

In the second example of this violation, the licensee had failed to adequately exercise

the core spray minimum flow check valves to the full stroke position required to fulfill

their safety function. The inspector noted that the initial test method had been

reclassified as a partial open test and the IST program revision of May 15,1995,

satisfactorily addressed the full flow test disassembly and inspection. The inspector

observed that testing and inspection to date was acceptable. This item is closed.

V. Management Meetings

X1 Exit Meeting Summary

The inspector presented the inspection results to members of licensee management at the

conclusion of the inspection on March 26,1998. The licensee acknowledged the findings

presented.

l

l

,

9

4

.

\ -

I PARTIAL LIST OF PERSONS CONTACTED

!

Licensee

1

l C. Peterson Regulatory Assurance Manager

l M. Fiumadore Design Engineering

l B. Weaver Work Analyst- Mechanical

R. Bozarth Modification Coordinator

M. Sullivan Construction Supervisor

i

INSPECTION PROCEDURES USED

l IP 37550 Engineering

l IP 37651 On-Site Engineering

IP 37700 Design, Design Changes, and Modifications

l

IP 37701 Facility Modifications

IP 37702 Design Changes and Modification Program

IP 92903 Follow-up - Engineering

'

ITEMS OPENED, CLOSED, AND DISCUSSED

,

Ooened i

!

50-254/98005-01 VIO proc violation work package prepared prior to design  ;

i approval

Closed

50-254/94004-16 URI pipe leaks over switchgear evaluation program

50-265/94004-10

50-254/94004-29 IFl EDGCW pump flow not evaluated

50-265/94004-29

50-254/94004-32 URI RHR valves not seat leak tested

50-265/94004-32

50-254/94004-44 IFl SESR process inadequately statused

50-265/94004-44

50-254/94004-49 IFl corp engineering support weaknesses i

'

50-265/94004-49

50-254/94020-03a,b,c; VIO 3 examples of corrective action violation

! 50-265/94020-03a,b,c

l 50-254/94020-04a,b VIO 2 examples of 50.55a (ASME IST) requirements violation

50-265/94020-04a,b

I

10

L____

- ______ _ - __________________________ __ ___ __ _

..

.

,

.

LIST OF ACRONYMS AND INITIALISMS USED

ASME American Society of Mechanical Engineers

CFR Code of Federal Regulations

Comed Commonwealth Edison Company

COA Course of Action

DCN Design Change Notice

DG Diesel Generator

DRS Division of Reactor Safety

EDGCWP Diesel Generator Cooling Water Pump

EDG Emergency Diesel Generator

IFl Inspection Follow-up Item

lOE Integrated Quality Report

IST In-Service Testing

LLRT Local Leak Rate Test

MAL Modification Approval Letter

NTS Nuclear Tracking System

PDR Public Document Room

PlF Problem Identification Form

QA Quality Assurance

OCAP Quad Cities Administrative Procedure

RCIC Reactor Core isolation Cooling

RHR Residual Heat Removal

SBLC Standby Liquid Control

SESR Site Engineering Service Request

TRB/SPG Technical Review Board / Site Planning Group

URI Unresolved item

VIO Violation

1

11

_ _ _ _ _ _ _ _ _ _ _ .